Amended under s67A 21 December 2006
ENVIRONMENTAL RISK MANAGEMENT AUTHORITY
DECISION
2 December 2003
Application Code
HSR03031
Application Type
To import or manufacture any hazardous substance
under Section 28 of the Hazardous Substances and New
Organisms (HSNO) Act 1996
Applicant
SC Johnson and Son Pty Ltd
Date Application Received
20 August 2003
Consideration Date
26 November 2003
Considered by
The Hazardous Substances Standing Committee of the
Authority
Purpose of the Application
To import Raid Fast Kill + 5 hour Mossie Protection +
Natural Pyrethrum, a household insecticide with
flammable properties with both contact and residual
insecticidal effects.
1
Summary of Decision
1.1
The application to import or manufacture Raid Fast Kill + 5 hour Mossie Protection +
Natural Pyrethrum is approved with controls in accordance with the relevant provisions
of the Hazardous Substances and New Organisms Act 1996 (the HSNO Act), the HSNO
Regulations, and the HSNO (Methodology) Order 1998.
1.2
The substance has been given the following unique identifier for the ERMA New
Zealand Hazardous Substances Register:

1.3
Raid Fast Kill + 5 hour Mossie Protection + Natural Pyrethrum
ERMA New Zealand has adopted the European Union use classification system as the
basis for recording the nature and uses of substances approved. The following use
categories are recorded for this substance:
Main Category:
4
Wide dispersive use
Industrial category:
5
Personal/domestic
Function/Use category:
39
Pesticides – non-agricultural
2
Legislative Criteria for Application
2.1
The application was lodged pursuant to section 28 of the HSNO Act. The decision was
determined in accordance with section 29, taking into account additional matters to be
considered in that section and matters relevant to the purpose of the Act, as specified
under Part II of the HSNO Act. Unless otherwise stated, references to section numbers
in this decision refer to sections of the HSNO Act.
2.2
Consideration of the application followed the relevant provisions of the Hazardous
Substances and New Organisms (Methodology) Order 1998 (the Methodology). Unless
otherwise stated, references to clauses in this decision refer to clauses of the
Methodology.
3
Application Process
3.1
The application was formally received on 20 August 2003.
3.2
The application was stalled on 26 August 2003, so that the applicant could provide more
detail on a number of matters in the application. The application was unstalled on 12
September 2003.
3.3
In accordance with sections 53(1) and 53A, and clauses 2(2)(b) and 7, public
notification was made on 15 September 2003.
3.4
Submissions closed on 28 October 2003. No submissions were received.
3.5
Various government departments (including the Ministry of Health, the Department of
Labour (Occupational Safety and Health) and the New Zealand Food Safety Authority
(Agricultural Compounds and Veterinary Medicines (ACVM) Group)), Crown Entities
and interested parties, which in the opinion of the Authority would be likely to have an
interest in the application, were notified of the receipt of the application (sections 53(4)
and 58(1)(c), and clauses 2(2)(e) and 5) and provided with an opportunity to comment
or make a public submission on the application.
3.6
The following response was received from the Ministry of Health:
“With appropriate HSNO controls, the Ministry has no issues to raise at this time
relating to the acceptance of this application based on the non-confidential information
provided from a public health perspective (non-occupational).”
3.7
No external experts were used in the considering of this application (clause 17).
3.8
A public hearing was not required to be held.
3.9
The following members drawn from the Hazardous Substances Standing Committee
considered the application (section 19(2)(b)): Mr Tony Haggerty and Dr Max Suckling.
ERMA New Zealand Decision: Application HSR03031
Page 2 of 24
3.10
The information available to the Committee comprised:
 The application, including confidential appendices
 The Evaluation and Review (E&R) Report
 Comments on the E & R Report provided by the applicant (24 November 2003).
4
Consideration
Purpose of the Application
4.1
The purpose of the application is to import Raid Fast Kill + 5 hour Mossie Protection +
Natural Pyrethrum, a domestic pesticide intended for control of flying and crawling
insects in the home.
Sequence of the Consideration
4.2
In accordance with clause 24, the approach adopted by the Committee was to:
 Establish the hazard classifications for the substance and derive the default
controls.
 Identify potentially non-negligible risks, costs, and benefits.
 Assess potentially non-negligible risks, costs, and benefits in the context of the
default controls and possible variations to those controls. Risks were assessed in
accordance with clause 12, and costs and benefits in accordance with clause 13.
 Consider and determine variations to the default controls arising from the
circumstances provided for in sections 77 (3), (4) and (5) and then consolidate
controls.
 Evaluate overall risks, costs, and benefits to reach a decision. The combined
impact of risks, costs and benefits was evaluated in accordance with clause 34,
and the cost-effectiveness of the application of controls was considered in
accordance with clause 35.
Hazard Classification
4.3
The Committee agreed with the Project Team’s hazard classification of the substance as
follows:
 2.1.2A (flammable aerosol)
 6.3B (skin irritant)
 6.5A (respiratory sensitiser)
 6.5B (contact sensitiser)
 9.1A (aquatic ecotoxicant)
 9.4A (terrestrial invertebrate toxicant)
Default Controls
4.4
The Committee considered that the E&R Report correctly assigned default controls as
set out in the HSNO Regulations. The default controls were used as the reference for
subsequent consideration of the application; they are identified in the E&R Report (in
Table 1 at paragraph 8.1) and are not reproduced here.
ERMA New Zealand Decision: Application HSR03031
Page 3 of 24
Identification of the Significant Risks, Costs and Benefits of the Substance
Risks
4.5
The Committee reviewed the identification of risks made in the E&R Report.
4.6
The human health risks relate to dermal sensitisation and irritancy, and inhalation
sensitisation. For this to occur, the substance would need to contact skin, or to be
inhaled by sensitised individuals.
4.7
Environmental health risks are considered to be insignificant to very low, but relate to
aquatic ecotoxicity and terrestrial invertebrate ecotoxicity, and to risks that could arise
from the substance causing acceleration of a fire.
Costs
4.8
A “cost” is defined in Regulation 2 of the Methodology as “the value of a particular
adverse effect expressed in monetary or non-monetary terms”. The Methodology and
the Act both call for consideration of monetary and non-monetary costs (clause 13 and
section 9).
4.9
The Committee considers that no new costs are likely to be associated with this
substance as the active ingredients are already in use in similar substances in New
Zealand.
Benefits
4.10
A “benefit” is defined in Regulation 2 of the Methodology as “the value of a particular
positive effect expressed in monetary or non-monetary terms”. Benefits that may arise
from any of the matters set out in clauses 9 and 11 were considered in terms of clause
13.
4.11
For this substance, the Committee agreed that the benefits discussed in the E & R
Report, as listed below, are likely to be realised:
 Increased consumer choice, including choice of active ingredients;
 Benefits to public health through the eradication of disease-carrying and annoying
pests.
4.12
The Committee notes that these benefits will accrue to a wide range of people.
4.13
The Committee is unable to place an expected value on the benefits (clause 13(b)) but is
satisfied that the ability of the applicant and others to use Raid Fast Kill + 5 hour
Mossie Protection + Natural Pyrethrum should give rise to the associated benefits.
Assessment of the Potentially Non-negligible Risks of the Substance
4.14
The risks assessed were those identified as potentially non-negligible. Risks were
considered in terms of the requirements of clause 12, including the assessment of
consequences and probabilities, the impact of uncertainty and the impact of risk
management.
ERMA New Zealand Decision: Application HSR03031
Page 4 of 24
4.15
The evidence available was largely scientific in nature and was considered in terms of
clause 25(1). This evidence comprised of that provided by the applicant and additional
evidence set out in the E&R Report.
4.16
In assessing risk, the Committee gave particular consideration to risks arising from the
significant hazards of the substance, i.e. human health effects, aquatic and terrestrial
invertebrate ecotoxicity, and the acceleration of fire, and examined the extent to which
exposure to hazard would be mitigated by controls (clauses 11 and 12).
4.17
The Committee is satisfied that risks to Māori, to society and the economy are
negligible with the controls in place, that the risks to human health are insignificant to
medium with the controls in place, and that the risks to the environment are
insignificant to very low.
Assessment of the Potentially Non-negligible Costs and Benefits
4.18
The Methodology and the Act both call for consideration of monetary and nonmonetary costs (clause 13 and section 9). The potentially non-negligible costs are
discussed in paragraphs 4.8 to 4.9. The Committee is satisfied that there are no
significant costs that will result from the release of the substance.
4.19
The potentially non-negligible benefits are listed in paragraph 4.11 of this decision
document. The Committee is unable to place an expected value on the benefits
(clause13(b)) but is satisfied that the ability of the applicant to enter the market could
give rise to the associated benefits.
Establishment of the Approach to Risk in the Light of Risk Characteristics
4.20
Clause 33 requires the Authority, when considering applications, to have regard for the
extent to which a specified set of risk characteristics exist. The intention of this
provision is to provide a route for determining how cautious or risk averse the Authority
should be in weighing up risks and costs against benefits.
4.21
The Committee has given consideration to section 3.4 of the Globally Harmonized
System of Classification and Labelling of Chemicals, in which it is noted that low level
warnings should be sufficient to mitigate the risks associated with sensitisers when
present at 0.1 - 1.0%. The Committee agrees with this, and notes that Control I16
requires such advice. The Committee also notes that exposure to this substance is
voluntary and will only impact on those sensitised individuals in the immediate vicinity.
4.22
In light of these risk characteristics, the Committee is satisfied that it can be less risk
averse in weighing up risks and costs against benefits.
Overall Evaluation of Risks, Costs and Benefits
4.23
Having regard to clauses 22 and 34 and in accordance with the tests in clause 27 and
section 29, risks, costs and benefits were evaluated taking account all proposed controls
including default controls plus proposed variations to the controls.
ERMA New Zealand Decision: Application HSR03031
Page 5 of 24
4.24
Clause 34 sets out the approaches available to the Authority in evaluating the combined
impact of risks, costs and benefits i.e. weighing up risks, costs and benefits.
Additional Controls under Section 77A
4.25
The Hazardous Substances (Pesticides) (Amendment) Transfer Notice 2006 states that,
unless specifically allowed for, no pesticide may be applied onto or into water. As Raid
Fast Kill + 5 Hour Mossie Protection + Natural Pyrethrum is not approved for such use,
the following control is applied to Raid Fast Kill + 5 Hour Mossie Protection + Natural
Pyrethrum:
Raid Fast Kill + 5 Hour Mossie Protection + Natural Pyrethrum must not be applied
directly onto or into water
Variation of Controls under Section 77
4.26
Under section 77(3), (4) and (5), the default controls determined by the hazardous
properties of the substance may be varied.
4.27
The applicant was given an opportunity to comment on the proposed controls as set out
in the E&R Report (clause 35(b)). The applicant’s comments, received by e-mail on 24
November 2003, were taken into account during the Committee’s consideration of this
application.
4.28
The Committee considered that the following variations should apply to Raid Fast Kill
+ 5 hour Mossie Protection + Natural Pyrethrum.
4.29
Control T1 (Regulations 11-27 of the Hazardous Substances (Classes 6, 8 and 9
Controls) Regulations), relates to the setting of TELs. This control is not applicable to
this substance, as the substance does not meet all requirements necessary for setting
acceptable daily exposure limits.
4.30
Control T2 (Regulations 29-30 of the Hazardous Substances (Classes 6, 8 and 9
Controls) Regulations) relates to the setting of Workplace Exposure Standards (WES).
The Committee considers that this control is not applicable to this substance when
imported as a formulated aerosol product. However, if Raid Fast Kill + 5 hour Mossie
Protection + Natural Pyrethrum were to be manufactured in New Zealand, then any
WES values that exist for individual components will apply.
4.31
Controls T4 and E6 are combined (section 77(5)) as they both relate to requirements for
equipment used to handle hazardous substances (Regulation 7 of the Hazardous
Substances (Classes 6, 8 and 9 Controls) Regulations).
4.32
Controls F2, T7 and E8 are combined (section 77(5)) as they each relate to the carriage
of hazardous substances on passenger service vehicles (Regulation 10 of Hazardous
Substances (Classes 6, 8 and 9) Controls Regulations and Regulation 8 of the Hazardous
Substances (Classes 1 to 5) Controls Regulations). Control F2 takes effect as the most
stringent control.
ERMA New Zealand Decision: Application HSR03031
Page 6 of 24
4.33
Controls D2, D4 and D5 are combined (section 77(5)) as they each relate to disposal
requirements (Regulations 6, 8 and 9 of the Hazardous Substances (Disposal)
Regulations. Control D2 takes effect as the most stringent control.
4.34
Control E1 (Regulations 32 -45 of the Hazardous Substances (Classes 6, 8 and 9
Controls) Regulations) refers to the setting of EELs. This control is deleted (section
77(4)(b)) as it is very unlikely that this substance will enter the environment in
sufficient quantities to cause adverse effects following normal use.
4.35
Control E2 (Regulations 46-48 of the Hazardous Substances (Classes 6, 8 and 9
Controls) Regulations) is not applicable to this substance as there is no requirement to
set an application rate for Raid Fast Kill + 5 hour Mossie Protection + Natural
Pyrethrum.
4.36
Control E3 (Regulation 40 of the Hazardous Substances (Classes 6, 8 and 9 Controls)
Regulations 2001 is for the protection of beneficial invertebrates, such as foraging bees.
As this substance is to be used in an indoor setting, this control is not applicable.
4.37
Control E5 (Regulations 5(2) and 6 of the Hazardous Substances (Classes 6, 8 and 9
Controls) Regulations 2001) relates to the keeping of records where large quantities of
this substance are discharged into air or water. The Committee considers that this
control is not applicable to this substance, as the requirements of this regulation are
unlikely to be met when the substance is used in the manner intended.
4.38
Controls E7 and TR1 (Regulation 9 of the Hazardous Substances (Classes 6, 8 and 9
Controls) Regulations, and Regulations 4(1), 5 and 6 of the Hazardous Substances
(Tracking) Regulations) relate to approved handlers and tracking of the substance.
These controls are deleted as provided by section 77(4)(b). The Committee considers
that this control would make it difficult for the benefits of the substance to be realised,
while not reducing the likelihood of adverse effects.
4.39
Control EM12 (Regulations 35-41 of the Hazardous Substances (Emergency
Management) Regulations) is deleted (section 77(4)(b)) as Raid Fast Kill + 5 hour
Mossie Protection + Natural Pyrethrum is not considered to be a pooling substance.
4.40
Control T5 (Regulation 8 of the Hazardous Substances (Classes 6, 8 and 9 Controls)
Regulations) describes requirements relating to the use of protective clothing and
equipment in workplaces. The Committee considers that this control is not relevant to
the domestic use of this substance. The Committee considers that infrequent, incidental
use of Raid Fast Kill + 5 hour Mossie Protection + Natural Pyrethrum in a workplace
poses the same risks as use in a domestic setting, and in these circumstances control T5
is not applicable. In both circumstances, the Committee considers that Control I16
(Regulation 25 of the Hazardous Substance (Identification) Regulations), which requires
the hazards of the substance to be identified, is sufficient for the sensitisation hazards to
be managed.
4.41
The HSNO Compressed Gas Regulations shall apply when promulgated. However,
until such time as the these regulations come into force, the Committee considers that
regulations 114(a) to (c) of the Dangerous Goods (Class 2 –Gases) Regulations 1980
relating to aerosol containers should be complied with.
ERMA New Zealand Decision: Application HSR03031
Page 7 of 24
Environmental User Charges
4.42
In the current absence of comprehensive criteria for undertaking such a consideration,
no consideration has been given to whether or not environmental user charges should be
applied to the substance which is the subject of this approval.
5
Decision
5.1
Pursuant to section 29 of the Act, the Committee has considered this application to
import a hazardous substance made under section 28 of the Act.
5.2
The Committee is satisfied that the default controls as varied in paragraph 4.29 to 4.41
will be adequate to manage the adverse effects of the hazardous substance.
5.3
Having considered all the possible effects of the hazardous substance in accordance
with section 29 of the Act, pursuant to clause 27 of the Methodology, based on
consideration and analysis of the information provided, and taking into account the
application of controls, the Committee is satisfied that the risks the substance poses to
the environment are insignificant to very low, and primarily arise from the potential of
the substance to accelerate a fire. An insignificant to medium level of risk to human
health and safety exists, being due to skin irritancy and to dermal and inhalation
sensitisation in some individuals. Despite this, it is evident that the benefits do
outweigh the costs. The application may therefore be approved in accordance with
clause 27.
5.4
In accordance with clause 36(2)(b) of the Methodology the Committee records that, in
reaching this conclusion, it has applied the balancing tests in section 29 of the Act and
clause 27 of the Methodology.
5.5
It has also applied the following criteria in the Methodology:
 clause 9 - equivalent of sections 5, 6 and 8;
 clause 11 – characteristics of substance;
 clause 12 – evaluation of assessment of risks;
 clause 13 – evaluation of assessment of costs and benefits;
 clause 14 – costs and benefits accruing to New Zealand;
 clause 21 – the decision accords with the requirements of the Act and regulations;
 clause 22 – the evaluation of risks, costs and benefits – relevant considerations;
 clause 24 – the use of recognised risk identification, assessment, evaluation and
management techniques;
 clause 25 – the evaluation of risks;
 clause 27 - risks and costs are outweighed by benefits;
 clause 33 – risk characteristics;
 clause 34 – the aggregation and comparison of risks, costs and benefits; and
 clause 35 – the costs and benefits of varying the default controls.
5.6
The application for importation and manufacture of the hazardous substance Raid Fast
Kill + 5 hour Mossie Protection + Natural Pyrethrum is thus approved under clause 27
with controls, as detailed in Appendix 1.
ERMA New Zealand Decision: Application HSR03031
Page 8 of 24
Tony Haggerty
Date 2 December 2003
Chair Hazardous Substances Committee
ERMA New Zealand Approval Code:
Raid Fast Kill + 5 hour Mossie Protection + Natural Pyrethrum:
HSR000087
Amendment December 2006
(a)
Addition of a s77A control stating:
Raid Fast Kill + 5 Hour Mossie Protection + Natural Pyrethrum must not
be applied directly onto or into water
Tony Haggerty
Date 21 December 2006
Chair
ERMA New Zealand Decision: Application HSR03031
Page 9 of 24
Appendix 1: List of Controls that apply to Raid Fast
Kill + 5 hour Mossie Protection + Natural Pyrethrum
Control
Code1
Regulation2
Explanation3
Hazardous Substances (Classes 1 to 5 Control Regulations) Regulations 2001 - Flammable Property
Controls
F1
Regulation 7
General test certification requirements for Raid Fast Kill + 5 hour
Mossie Protection + Natural Pyrethrum
Where a test certificate is required for a hazardous substance location
holding Raid Fast Kill + 5 hour Mossie Protection + Natural Pyrethrum, that
test certificate must be issued by an approved test certifier and must typically
be renewed yearly. However, the Authority can, on request by the persons
required to obtain the test certificate, extend the time period to three years.
F3
Regulation 55
General limits on flammable substances
Where Raid Fast Kill + 5 hour Mossie Protection + Natural Pyrethrum is
present at a place for longer than 18 hours, and in a quantity that exceeds
3000 L (aggregate water capacity), it must be held at a hazardous
substance location (or transit depot as appropriate).
F4
Regulation 56
Certain flammable substances to be under the control of an approved
handler
When Raid Fast Kill + 5 hour Mossie Protection + Natural Pyrethrum is held
in quantities above 3000 L (aggregate water capacity), it must be under the
control of an approved handler or secured to a specified standard.
F5
It should be noted that any person handling any quantity of Raid Fast Kill +
5 hour Mossie Protection + Natural Pyrethrum under any of Regulations 61,
63(4), 65, 67 and 69 must be an approved handler for that substance, i.e. the
trigger quantities that typically activate approved handler requirements do
not apply (Regulation 60(2)).
Regulations 58- Requirements regarding hazardous atmosphere zones for Raid Fast Kill
59
+ 5 hour Mossie Protection + Natural Pyrethrum
There is a requirement to establish a hazardous atmosphere zone wherever
Raid Fast Kill + 5 hour Mossie Protection + Natural Pyrethrum is present in
quantities greater than 3000 L (aggregate water capacity). The zone must
comply with either of the standards as listed in Regulation 58(a)-(b) or an
ERMA approved code of practice.
There are a number of requirements that must be met regarding hazardous
atmosphere zones, including:
 any controls placed on electrical systems or electrical equipment
within a hazardous atmosphere zone must be consistent with any
controls on electrical systems or electrical equipment set under other
legislation that are relevant to that specific location. This is to
ensure that any potential ignition sources from electrical system or
electrical equipment are protected or insulated to an extent that is
1
Note: The numbering system used in this column relates to the coding system used in the ERMA New Zealand Controls Matrix. This links the
hazard classification categories to the regulatory controls triggered by each category. It is available from ERMA New Zealand and is also
contained in the ERMA New Zealand User Guide to the Controls Regulations.
2
These Regulations form the controls applicable to this substance. Refer to the cited Regulations for the formal specification, and for definitions
and exemptions. The accompanying explanation is intended for guidance only.
3
These explanations are for guidance only. Refer to the cited Regulations for the formal specification, and for definitions and exemptions.
ERMA New Zealand Decision: Application HSR03031
Page 10 of 24
Control
Code1
F6
F11
F12
Regulation2
Explanation3
consistent with the degree of hazard (Regulation 59)
 test certification requirements (Regulation 81).
Regulations 60- Requirements to prevent unintended ignition of Raid Fast Kill + 5 hour
70
Mossie Protection + Natural Pyrethrum
These regulations prescribe controls to reduce the likelihood of unintended
ignition of Raid Fast Kill + 5 hour Mossie Protection + Natural Pyrethrum.
Controls are prescribed with the aim of covering all foreseeable
circumstances in which unintended ignition could take place, and include:
 placing limits on the proportion of flammable vapour to air to ensure that
the proportion of flammable vapour to air will always be sufficiently
outside the flammable range, so that ignition cannot take place, and
 ensuring that there is insufficient energy available for ignition. This
energy could be in the form of either temperature or ignition energy (eg.
a spark). Accordingly, the controls provide two approaches to ensure
that there is insufficient energy for ignition:
(1) keeping the temperature of the substance, or the temperature of any
surface in contact with the substance, below 80% of the auto-ignition
temperature of the substance, and
(2) keeping sources of ignition below the minimum ignition energy, either
by removal of the ignition source from any location where flammable
substances are handled, or by protecting the “general” mass of
flammable material from the ignition source, eg. by enclosing any
ignition sources in an enclosure that will not allow the propagation of the
flame to the outside; or using flameproof motors especially designed to
prevent ignition energy escaping.
It should be noted that any person handling any quantity of Raid Fast Kill +
5 hour Mossie Protection + Natural Pyrethrum under any of Regulations 65,
67 and 69 must be an approved handler for that substance, i.e. the trigger
quantities that typically activate approved handler requirements do not apply
(Regulation 60(2)).
Regulation 76
Segregation of incompatible substances
In order to reduce the likelihood of unintended ignition of flammable
substances, there is a requirement to ensure that Raid Fast Kill + 5 hour
Mossie Protection + Natural Pyrethrum does not come into contact with any
incompatible substance or material. A list of substances and materials
considered incompatible with Raid Fast Kill + 5 hour Mossie Protection +
Natural Pyrethrum is provided in Table 1 of Schedule 3 (Classes 1 to 5
Controls Regulations).
Regulations 77- General requirement for hazardous substance locations for Raid Fast
78
Kill + 5 hour Mossie Protection + Natural Pyrethrum
There is a requirement to establish a hazardous substance location where
Raid Fast Kill + 5 hour Mossie Protection + Natural Pyrethrum is present in
quantities greater than 3000 L (aggregate water capacity) and for a period
exceeding 18 hours.
Within such zones, there is a requirement for the person in charge to:
 notify the responsible enforcement authority of the locality and capacity
of the hazardous substance location
 where relevant, ensure that the substance will be under the control of an
approved handler and that any container/building used to hold the
substances is secured
 ensure that any test certification requirements are met
ERMA New Zealand Decision: Application HSR03031
Page 11 of 24
Control
Code1
Regulation2
F14
Regulation 81
F16
Regulation 83
Explanation3
 ensure that a site plan is available for inspection
 where required, establish and manage a hazardous atmosphere zone.
A number of controls are prescribed for hazardous substance locations in
order to reduce the likelihood of unintended ignition, including:
 requirements for fire resistant walls (240/240/240 minutes) and
separation distances (greater than 3m) to isolate any ignition sources
 safety requirements for electrical equipment (construction, design,
earthing)
 requirements for segregation of incompatible substances.
Test certification requirements for facilities where Raid Fast Kill + 5
hour Mossie Protection + Natural Pyrethrum is present
There is a test certification requirement when Raid Fast Kill + 5 hour Mossie
Protection + Natural Pyrethrum is present at any hazardous substance
location, hazardous atmosphere zone or transit depot when in quantities
above 3000 L (aggregate water capacity).
That test certificate must be issued by an approved test certifier and must
demonstrate compliance with a number of specified controls, including:
 notification to relevant enforcement officer of hazardous substance
location
 approved handler requirements
 security requirements
 hazardous atmosphere zone requirements, including controls on
electrical systems and electrical equipment
 segregation of incompatible substances
 signage requirements
 emergency management requirements
 fire-fighting equipment
 secondary containment.
Controls on transit depots where Raid Fast Kill + 5 hour Mossie
Protection + Natural Pyrethrum is present
Transit depots are places designed to hold hazardous substances (in
containers that remain unopened) for a period of up to three days, but for
periods that are more than 18 hours.
Whenever Raid Fast Kill + 5 hour Mossie Protection + Natural Pyrethrum is
held at a transit depot in quantities exceeding 3000 L (aggregate water
capacity), there is a requirement for the person in charge to:
 notify the responsible enforcement authority of the locality and capacity
of the hazardous substance location
 where relevant, ensure that the substance will be under the control of an
approved handler
 ensure that any road vehicle loaded with containers of Raid Fast Kill + 5
hour Mossie Protection + Natural Pyrethrum is within specified
distances of other vehicles or places containing hazardous substances
 ensure that containers of Raid Fast Kill + 5 hour Mossie Protection +
Natural Pyrethrum held in the depot (but not loaded onto a vehicle) are
within specified distances from vehicles or other containers
 ensure that the substance remains in its containers and the containers
remain closed
 ensure the safety of any electrical equipment
ERMA New Zealand Decision: Application HSR03031
Page 12 of 24
Control
Code1
F17
Regulation2
Explanation3
 comply with any signage requirements
 comply with relevant parts of other Acts and Regulations, eg. Electricity
Act 1992, HSE (Mining Underground Regulations) 1999 or Civil
Aviation Rules.
Regulations 84- Requirements to control adverse effects of intended ignition of
85
flammable substances, including requirements for protective equipment
and clothing
These controls are intended to ensure that where Raid Fast Kill + 5 hour
Mossie Protection + Natural Pyrethrum is intentionally burnt, the effects of
combustion are managed:
 to ensure that adverse effects are contained within the intended area, and
 to prevent people being exposed to harmful levels of heat radiation.
Regulation 84(1) prescribes controls relating to the maximum level of heat
radiation that a person may be exposed to whenever Raid Fast Kill + 5 hour
Mossie Protection + Natural Pyrethrum is intentionally burnt. If the
intended combustion involves burning substances at a rate in excess of
20kg/hour or 20L/hour, there is an additional requirement for the person in
charge to establish a combustion zone around the intended combustion area
(Regulation 84(2)). The person in charge of the combustion zone must
ensure that:
 the enforcement officer has been notified of the combustion zone’s
location
 the combustion zone encompasses all areas where there is the potential
for people to be exposed to a higher degree of heat radiation than the
level specified in Regulation 84(1)(b)
 a site plan of the combustion zone is available at all times
 all non-authorised personnel are excluded from the combustion zone
 the level of heat radiation outside the combustion zone at no exceeds the
level specified in Regulation 84(1)(b)
 there is appropriate signage around the perimeter of the zone warning
that combustion is occurring and prohibiting entry into the zone.
For those situations where the level of heat radiation within a combustion
zone may exceed the level specified in Regulation 84(1)(b), there is a
requirement for the person in charge to ensure that all people entering the
combustion zone have the appropriate protective clothing and equipment
(Regulation 85). Specific requirements are prescribed relating to the design,
construction and use of the protective clothing and equipment, including:
 they must be designed, constructed and operated to prevent any person
being subjected to more than the level of heat radiation specified in
Regulation 84(1)(b)
 they must either be constructed of materials that are not degraded,
attacked or combusted by the substance under the expected use
conditions, or if they are not completely resistant, they must retain their
integrity for the time specified by the supplier.
 they must be accompanied by documentation that gives sufficient
instruction on their use and maintenance.
Hazardous Substances (Classes 6, 8 and 9 Controls) Regulations 2001 -Toxic Property Controls
T4 and E6
Regulation 7
Requirements for equipment used to handle hazardous substances
Any equipment used to handle Raid Fast Kill + 5 hour Mossie Protection +
ERMA New Zealand Decision: Application HSR03031
Page 13 of 24
Control
Code1
Explanation3
Natural Pyrethrum (eg. spray equipment) must retain and/or dispense the
substance in the manner intended, i.e. without leakage, and must be
accompanied by sufficient information so that this can be achieved.
Hazardous Substances (Classes 6, 8 and 9 Controls) Regulations 2001 - Ecotoxic Property Controls
F2, E8
and T7
Regulation2
Regulation 10
Restrictions on the carriage of Raid Fast Kill + 5 hour Mossie Protection
+ Natural Pyrethrum on passenger service vehicles
In order to limit the potential for public exposure to hazardous substances,
the maximum quantity per package permitted to be carried on a passenger
service vehicle is 1000mL (aggregate water capacity).
Hazardous Substances (Identification) Regulations 2001
I1
Regulations 6,
7, 32-35, 36
(1)-(7)
The Identification Regulations prescribe requirements with regard to
identification of Raid Fast Kill + 5 hour Mossie Protection + Natural
Pyrethrum in terms of:
 information that must be “immediately available” with the substance
(priority and secondary identifiers). This information is generally
provided by way of the product label
 documentation that must be available in the workplace, generally
provided by way of MSDS
 signage at a place where there is a large quantity of the substance.
General identification requirements
These controls relate to the duties of suppliers and persons in charge of Raid
Fast Kill + 5 hour Mossie Protection + Natural Pyrethrum with respect to
identification (essentially labelling) (Regulations 6 and 7), accessibility of
the required information (Regulations 32 and 33) and presentation of the
required information with respect to comprehensibility, clarity and durability
(Regulations 34, 35, 36(1)-(7))
Regulation 6 – Identification duties of suppliers
Suppliers of Raid Fast Kill + 5 hour Mossie Protection + Natural Pyrethrum
must ensure it is labelled with all relevant priority identifier information (as
required by Regulations 8-17) and secondary identifier information (as
required by Regulations 18-30) before supplying it to any other person. This
includes ensuring that the priority identifier information is available to any
person handling the substance within two seconds (Regulation 32), and the
secondary identifier information available within 10 seconds (Regulation
33).
Suppliers must also ensure that no information is supplied with the substance
(or its packaging) that suggests it belongs to a class that it does not in fact
belong to.
Regulation 7 – Identification duties of persons in charge
Persons in charge of Raid Fast Kill + 5 hour Mossie Protection + Natural
Pyrethrum must ensure it is labelled with all relevant priority identifier
information (as required by Regulations 8 to 17) and secondary identifier
information (as required by Regulations 18 to 30) before supplying it to any
other person. This includes ensuring that the priority identifier information is
available to any person handling the substance within two seconds
(Regulation 32), and the secondary identifier information available within 10
ERMA New Zealand Decision: Application HSR03031
Page 14 of 24
Control
Code1
Regulation2
Explanation3
seconds (Regulation 33).
Persons in charge must also ensure that no information is supplied with the
substance (or its packaging) that suggests it belongs to a class that it does not
in fact belong to.
Regulations 32 and 33 – Accessibility of information
All priority identifier Information (as required by Regulations 8 to 17) must
be available within 2 seconds, eg. on the label.
All secondary identifier Information (as required by Regulations 18 to 30)
must be available within 10 seconds, eg. on the label.
I3
I5
I9
Regulation 9
Regulation 11
Regulation 18
Regulations 34, 35, 36(1)-(7) – Comprehensibility, Clarity and Durability of
information
All required priority and secondary identifiers must be presented in a way
that meets the performance standards in these Regulations. In summary:
 any information provided (either written and oral) must be readily
understandable and in English
 any information provided in written or pictorial form must be able to be
easily read or perceived by a person with average eyesight under normal
lighting conditions
 any information provided in an audible form must be able to be easily
heard by a person with average hearing
 any information provided must be in a durable format i.e. the information
requirements with respect to clarity must be able to be met throughout
the lifetime of the (packaged) substance under the normal conditions of
storage, handling and use.
Priority identifiers for ecotoxic substances
This requirement specifies that Raid Fast Kill + 5 hour Mossie Protection +
Natural Pyrethrum must be prominently identified as being ecotoxic.
This information must be available to any person handling the substance
within two seconds (Regulation 32) and can be provided by way of signal
headings or commonly understood pictograms on the label.
Priority identifiers for flammable substances
This requirement specifies that Raid Fast Kill + 5 hour Mossie Protection +
Natural Pyrethrum must be prominently identified as being a flammable
aerosol.
This information must be available to any person handling the substance
within two seconds (Regulation 32) and can be provided by way of signal
headings or commonly understood pictograms on the label.
Secondary identifiers for all hazardous substances
This control relates to detail required for Raid Fast Kill + 5 hour Mossie
Protection + Natural Pyrethrum on the product label. This information must
be accessible within 10 seconds (Regulation 33) and could be provided on
secondary panels on the product label. The following information is
required:
 an indication (which may include its common name, chemical name, or
registered trade name) that unequivocally identifies it, and
 enough information to enable its New Zealand importer, supplier, or
ERMA New Zealand Decision: Application HSR03031
Page 15 of 24
Control
Code1
Regulation2
I11
Regulation 20
I13
Regulation 22
I16
Regulation 25
I17
Regulation 26
Explanation3
manufacturer to be contacted, either in person or by telephone, and
 in the case of a substance which, when in a closed container, is likely to
become more hazardous over time or develop additional hazardous
properties, or become a hazardous substance of a different class, a
description of each likely change and the date by which it is likely to
occur.
Secondary identifiers for ecotoxic substances
This control relates to the additional label detail required for Raid Fast Kill +
5 hour Mossie Protection + Natural Pyrethrum. This information must be
accessible within 10 seconds (Regulation 33) and could be provided on
secondary panels on the product label. The following information must be
provided:
 an indication of the circumstances in which it may harm living organisms
 an indication of the kind and extent of the harm it is likely to cause to
living organisms
 an indication of the steps to be taken to prevent harm to living organisms
 an indication of its general type and degree of hazard (eg. very toxic to
aquatic life, ecotoxic to terrestrial invertebrates)
Secondary identifiers for flammable substances
This control relates to the additional label detail required for flammable
substances. This information must be accessible within 10 seconds
(Regulation 33) and could be provided on secondary panels on the product
label. The following information must be provided:
 an indication of its general type and degree of flammable hazard (eg.
flammable aerosol)
 an indication of the circumstances in which it may be ignited
unintentionally
 an indication of the likely effect of an unintentional ignition
 an indication of the steps to be taken to prevent an unintentional ignition.
Secondary identifiers for toxic substances
This control relates to the additional label detail required for Raid Fast Kill +
5 hour Mossie Protection + Natural Pyrethrum. This information must be
accessible within 10 seconds (Regulation 33) and could be provided on
secondary panels on the product label. The following information must be
provided:
 an indication of its general type and degree of toxic hazard (eg. contact
and respiratory sensitiser, and skin irritant)
 an indication of the circumstances in which it may harm human beings
 an indication of the kinds of harm it may cause to human beings, and the
likely extent of each kind of harm
 an indication of the steps to be taken to prevent harm to human beings
 the name and concentration of any ingredient that would independently
of any other ingredient, cause the substance to be classified as either
6.5A or 6.5B
Use of Generic Names
This control provides the option of using a generic name to identify specific
ingredients (or groups of ingredients) where such ingredients are required to
be listed on the product label as specified by Regulations 19(f) and 25(e) and
(f).
(Regulations 19(f) and 25(e) and (f) specify a requirement to list on the
product label, the name and concentration of any ingredient that would
ERMA New Zealand Decision: Application HSR03031
Page 16 of 24
Control
Code1
Regulation2
I18
Regulation 27
I19
Regulations
29-31
Explanation3
independently of any other ingredient, cause the substance to be classified as
6.5A or 6.5B.
Use of Concentration Ranges
This control provides the option of providing concentration ranges for those
ingredients whose concentrations are required to be stated on the product
label as specified by Regulations 19(f) and 25(e) and (f).
(Regulations 19(f) and 25(e) and (f) specify a requirement to list on the
product label, the name and concentration of any ingredient that would
independently of any other ingredient, cause the substance to be classified as
either 6.5A or 6.5B.
Alternative information in certain cases
Regulation 29 – Substances in fixed bulk containers or bulk transport
containers
This Regulation relates to alternative ways of presenting the priority and
secondary identifier information required by Regulations 8 to 25 when
substances are contained in fixed bulk containers or bulk transport
containers.
Regulation 29(1) specifies that for fixed bulk containers, it is sufficient
compliance if there is available at all times to people near the container,
information that identifies the type and general degree of hazard of the
substance.
Regulation 29(2) specifies that for bulk transport containers, it is sufficient
compliance if the substance is labelled or marked in compliance with the
requirements of the Land Transport Rule 45001 or Maritime Transport Act
1994.
Regulation 30 – Substances in multiple packaging
This Regulation relates to situations when Raid Fast Kill + 5 hour Mossie
Protection + Natural Pyrethrum is in multiple packaging and the outer
packaging obscures some or all of the required substance information. In
such cases, the outer packaging must:
 be clearly labelled with all relevant priority identifier information i.e. the
hazardous properties of the substance must be identified, or
 be labelled or marked in compliance with either the Land Transport Rule
45001, Civil Aviation Act 1990 or the Maritime Safety Act 1994 as
relevant, or
 in the case of an ecotoxic substance, it must bear the EU pictogram
“Dangerous to the Environment” (‘dead fish and tree’ on orange
background), or
 bear the relevant class label assigned by the UN Model Regulations.
Regulation 31 – Alternative information when Raid Fast Kill + 5 hour
Mossie Protection + Natural Pyrethrum is imported
This Regulation relates to alternative information requirements for Raid Fast
Kill + 5 hour Mossie Protection + Natural Pyrethrum if imported into New
Zealand in a closed package or in a freight container and will be transported
to its destination without being removed from that package or container. In
these situations, it is sufficient compliance with HSNO if the package or
container is labelled or marked in compliance with the requirements of the
Land Transport Rule 45001.
ERMA New Zealand Decision: Application HSR03031
Page 17 of 24
Control
Code1
I21
Regulation2
Regulations
37-39, 47-50
Explanation3
Documentation required in places of work
These controls relate to the duties of suppliers and persons in charge of
places of work with respect to provision of documentation (essentially
Material Safety Data Sheets) (Regulations 37, 38 and 50); the general
content requirements of the documentation (Regulation 39 and 47); the
accessibility and presentation of the required documentation with respect to
comprehensibility and clarity (Regulation 48). These controls are
triggered when Raid Fast Kill + 5 hour Mossie Protection + Natural
Pyrethrum is held in the workplace in quantities equal to or greater
than 1 L aggregate water capacity (equivalent to four 250mL cans of
Raid Fast Kill + 5 hour Mossie Protection + Natural Pyrethrum), using
the flammable aerosol level.
Regulation 37 – Documentation duties of suppliers
A supplier must provide documentation containing all relevant information
required by Regulations 39 to 46 when selling or supplying to another person
a quantity of Raid Fast Kill + 5 hour Mossie Protection + Natural Pyrethrum
equal to or greater than 1 L aggregate water capacity, if the substance is to be
used in a place of work and the supplier has not previously provided the
documentation to that person.
Regulation 38 – Documentation duties of persons in charge of places of work
The person in charge of any place of work where Raid Fast Kill + 5 hour
Mossie Protection + Natural Pyrethrum is present in quantities equal to or
greater than those specified in Regulation 38 (and with reference to Schedule
2 of the Identification Regulations), must ensure that every person handling
the substance has access to the documentation containing all relevant
information required by Regulations 39 to 46. The person in charge must
also ensure that the documentation does not contain any information that
suggests that the substance belongs to a hazard classification it does not in
fact belong to.
Regulation 39 – General content requirements for documentation
The documentation provided with Raid Fast Kill + 5 hour Mossie Protection
+ Natural Pyrethrum must include the following information:
 the unequivocal identity of the substance (eg. the CAS number, chemical
name, common name, UN number, registered trade name(s))
 a description of the physical state, colour and odour of the substance
 if the substance’s physical state may alter over the expected range of
workplace temperatures, the documentation must include a description of
the temperatures at which the changes in physical state may occur and
the nature of those changes.
 in the case of a substance that, when in a closed container, is likely to
become more hazardous over time or develop additional hazardous
properties, or become a hazardous substance of a different class, the
documentation must include a description of each likely change and the
date by which it is likely to occur
 contact details for the New Zealand supplier/manufacturer/importer
 all emergency management and disposal information required for the
substance
 the date on which the documentation was prepared
 the name, concentration and CAS number of any ingredients that would
ERMA New Zealand Decision: Application HSR03031
Page 18 of 24
Control
Code1
Regulation2
Explanation3
independently of any other ingredient, cause the substance to be
classified as a class 6.5.
Regulation 47 – Information not included in approval
This Regulation relates to the provision of specific documentation
information (eg. as provided on an MSDS). If information required by
Regulations 39 to 46 was not included in the information used for the
approval of the substance by the Authority, it is sufficient compliance with
those Regulations if reference is made to that information requirement along
with a comment indicating that such information is not applicable to that
substance.
Regulation 48 – Location and presentation requirements for documentation
All required documentation must be available to a person handling the
substance in a place of work within 10 minutes. The documentation must be
readily understandable by any fully-trained worker required to have access to
it and must be easily read, under normal lighting conditions, at a distance of
not less than 0.3m.
Regulation 49 – Documentation requirements for vehicles
This Regulation provides for the option of complying with documentation
requirements as specified in the various Land, Sea and Air transport rules
when the substance is being transported.
I23
Regulation 41
I25
Regulation 43
Regulation 50 – Documentation to be supplied on request
Notwithstanding Regulation 37 above, a supplier must provide the required
documentation to any person in charge of a place of work (where Raid Fast
Kill + 5 hour Mossie Protection + Natural Pyrethrum is present) if asked to
do so by that person.
Specific documentation requirements for ecotoxic substances
The documentation provided with Raid Fast Kill + 5 hour Mossie Protection
+ Natural Pyrethrum must include the following information:
 its general degree and type of ecotoxic hazard (eg. highly ecotoxic to
terrestrial invertebrates)
 a full description of the circumstances in which it may harm living
organisms and the extent of that harm
 a full description of the steps to be taken to prevent harm to living
organisms
 a summary of the available acute and chronic (ecotox) data used to
define it as being in classes 9.1A and 9.4B.
 its bio-concentration factor or octanol-water partition coefficient
 its expected soil or water degradation rate
Specific documentation requirements for flammable substances
The documentation provided with Raid Fast Kill + 5 hour Mossie Protection
+ Natural Pyrethrum must include the following information:
 its general degree and type of hazard
 a full description of the circumstances in which it may be ignited
unintentionally
 the likely effect of an unintentional ignition
 a full description of the steps to be taken to prevent an unintentional
ignition
ERMA New Zealand Decision: Application HSR03031
Page 19 of 24
Control
Code1
I28
I29
Regulation2
Regulation 46
Regulations
51-52
Explanation3
Specific documentation requirements for toxic substances
The documentation provided with Raid Fast Kill + 5 hour Mossie Protection
+ Natural Pyrethrum must include the following information:
 its general degree and type of toxic hazard
 a full description of the circumstances in which it may harm human
beings
 the kinds of harm it may cause to human beings
 a full description of the steps to be taken to prevent harm to human
beings
 its vapour pressure, and the temperature at which that pressure was
measured
 if it will be a liquid during its use, the percentage of volatile substance in
the liquid formulation, and the temperature at which the percentages
were measured
 a summary of the available acute and chronic (toxic) data used to define
the substance as being in classes 6.5A and 6.5B.
 the symptoms or signs of injury or ill health associated with each likely
route of exposure
 the dose, concentration, or conditions of exposure likely to cause injury
or ill health
Duties of persons in charge of places with respect to signage
These controls specify the requirements for signage, in terms of content,
presentation and positioning at places where Raid Fast Kill + 5 hour Mossie
Protection + Natural Pyrethrum is held in quantities exceeding 3000 litres
(aggregate water capacity), using the flammable aerosol level. This is
equivalent to 12000 cans of Raid Fast Kill + 5 hour Mossie Protection +
Natural Pyrethrum.
Signs are required:
 at every entrance to the building and/or location (vehicular and
pedestrian) where hazardous substances are present
 at each entrance to rooms or compartments where hazardous substances
are present
 immediately adjacent to the area where hazardous substances are located
in an outdoor area.
The information provided in the signage needs to be understandable over a
distance of 10 metres and be sufficient to:
 advise that the location contains hazardous substances
 describe the general type and degree of hazard of the substance (eg.
highly flammable)
 where the signage is immediately adjacent to the hazardous substance
storage areas, describe the precautions needed to safely manage the
substance (eg. a 'No Smoking' warning near flammable substances).
Hazardous Substances (Disposal) Regulations 2001
D2, D4,
D5
Regulation 6,
8, 9
Disposal requirements for flammable substances
Raid Fast Kill + 5 hour Mossie Protection + Natural Pyrethrum must be
disposed of by:
 treating the substance so that it is no longer a hazardous substance.
Treatment does not include depositing the substance in a landfill or
sewage facility but can include controlled burning providing that the
ERMA New Zealand Decision: Application HSR03031
Page 20 of 24
Control
Code1
D6
D7
D8
Regulation2
Explanation3
performance requirements as set out in Regulation 6(3)(b) of the
Disposal Regulations for protecting people and the environment are met;
or
 exporting the substance from New Zealand as a hazardous waste, or
 by discharge into the environment as waste or deposited in a landfill,
provided the discharge location is managed so that:
 the substance will not at any time come into contact with any substances
with explosive or oxidising properties; and
 there is no ignition source in the vicinity of the disposal site; and
 in the event of an accidental fire, harm to people or the environment does
not occur – the performance requirements for this are set out in
Regulation 6(3)(b) of the Disposal Regulations.
Regulation 10
Disposal requirements for packages
This control gives the disposal requirements for packages that contained
Raid Fast Kill + 5 hour Mossie Protection + Natural Pyrethrum and are no
longer to be used for that purpose. Such packages must be either
decontaminated/treated or rendered incapable of containing any substance
(hazardous or otherwise) and then disposed of in a landfill or by recycling.
Regulations 11, Disposal information requirements
12
These controls relate to the provision of information concerning disposal
(essentially on the label) that must be provided when selling or supplying
any quantity of Raid Fast Kill + 5 hour Mossie Protection + Natural
Pyrethrum.
Information must be provided on appropriate methods of disposal and
information may be supplied warning of methods of disposal that should be
avoided i.e. that would not comply with the Disposal Regulations. Such
information must be accessible to a person handling the substance within 10
seconds and must comply with the requirements for comprehensibility,
clarity and durability as described in Regulations 34-36 of the Identification
Regulations (code I1).
Regulations 13, Disposal documentation requirements
14
These controls relate to the provision of documentation concerning disposal
(essentially in a MSDS) that must be provided when selling or supplying a
quantity of Raid Fast Kill + 5 hour Mossie Protection + Natural Pyrethrum.
This is triggered above 1 litre aggregate water capacity (equivalent to four
cans of Raid Fast Kill + 5 hour Mossie Protection + Natural Pyrethrum),
using the flammable aerosol level.
The documentation must describe one or more methods of disposal (that
comply with the Disposal Regulations) and describe any precautions that
must be taken. Such documentation must be accessible to a person handling
the substance at a place of work within 10 minutes and must comply with
the requirements for comprehensibility and clarity as described in
Regulations 48(2), (3) and (4) of the Identification Regulations (code I21).
Hazardous Substances (Emergency Management) Regulations 2001
EM1
Regulations 6,
7, 9-11
Level 1 emergency management information: General requirements
These controls relate to the provision of emergency management information
(essentially on the label) that should be provided with any hazardous
substance when present in quantities equal to or greater than the trigger
levels as listed in Schedule 1 of the Emergency Management Regulations.
ERMA New Zealand Decision: Application HSR03031
Page 21 of 24
Control
Code1
Regulation2
Explanation3
Regulation 6 describes the duties of suppliers, Regulation 7 describes the
duties of persons in charge of places, Regulation 9 describes the requirement
for the availability of the information (10 seconds) and Regulation 10 gives
the requirements relating to the presentation of the information with respect
to comprehensibility, clarity and durability. These requirements correspond
with those relating to secondary identifiers required by the Identification
Regulations (code I1, Regulations 6, 7, 32–35, 36(1)-(7)).
Regulation 11 provides for the option of complying with the information
requirements of the transport rules when the substance is being transported.
EM4
Regulation 8(c)
EM6
Regulation 8(e)
EM7
EM8
Regulation 8(f)
Regulations
12-16, 18-20
Using the flammable aerosol level, the trigger quantity that should apply is 1
L (aggregate water capacity).
Additional information requirements for flammable substances
The following information must be provided with this substance when
present in quantities equal to or greater than 1 L (aggregate water capacity):
 a description of the material and equipment needed to put out a fire
involving it
Information requirements for toxic substances
The following information should be provided when Raid Fast Kill + 5 hour
Mossie Protection + Natural Pyrethrum is present in quantities equal to or
greater than the trigger levels as listed in Schedule 1 of the Emergency
Management Regulations:
 a description of the usual symptoms of exposure
 a description of the first aid to be given
 a 24-hour emergency service telephone number.
It is recommended that this information be provided when the substance is
present at and above 1 L (aggregate water capacity).
Information requirements for ecotoxic substances
The following information should be provided with Raid Fast Kill + 5 hour
Mossie Protection + Natural Pyrethrum when present in quantities equal to or
greater than the trigger levels as listed in Schedule 1 of the Emergency
Management Regulations.
 a description of the parts of the environment likely to be immediately
affected by it:
 a description of its typical effects on those parts of the environment
 a statement of any immediate actions that may be taken to prevent
the substance from entering or affecting those parts of the
environment.
It is recommended that this information be provided when the substance is
present at and above 1 L (aggregate water capacity).
Level 2 emergency management information requirements
These controls relate to the duties of suppliers and persons in charge of
places of work with respect to the provision of emergency management
documentation (essentially Material Safety Data Sheets). This
documentation must be provided where Raid Fast Kill + 5 hour Mossie
Protection + Natural Pyrethrum is sold or supplied, or held in a workplace, in
quantities equal to or greater than 1 litre aggregate water capacity,
being equivalent to four cans of Raid Fast Kill + 5 hour Mossie
Protection + Natural Pyrethrum. This uses the level triggered for
ERMA New Zealand Decision: Application HSR03031
Page 22 of 24
Control
Code1
Regulation2
Explanation3
flammable aerosols.
Regulations 12 and 13 describe the duties of suppliers, Regulation 14
describes the duties of persons in charge of places of work, Regulation 15
provides for the option of complying with documentation requirements of the
transport rules when the substance is being transported, and Regulation 16
specifies requirements for general contents of the documentation.
EM9
Regulation 17
EM10
Regulations
21-24
EM11
EM13
Regulations
25-34
Regulation 42
Regulation 18 provides accessibility requirements (documentation to be
available within five minutes) and Regulation 19 provides requirements for
presentation with respect to comprehensibility and clarity. These
requirements correspond with those relating to documentation required by
the Identification Regulations (code I21).
Extra content for flammable substances
There is an additional requirement for Raid Fast Kill + 5 hour Mossie
Protection + Natural Pyrethrum that a description be provided of the steps to
be taken to control any fire involving the substance, including the types of
extinguishant to be used.
Fire extinguishers
Every place (including vehicles) where Raid Fast Kill + 5 hour Mossie
Protection + Natural Pyrethrum is held in a place of work in quantities
exceeding 3000 L (aggregate water capacity), must have one fire
extinguisher (Regulation 21). The intention of these general requirements is
to provide sufficient fire-fighting capacity to stop a fire spreading and
reaching hazardous substances, rather than providing sufficient capacity to
extinguish any possible fire involving large quantities of hazardous
substances.
Each fire extinguisher must be located within 30m of the substance, or, in a
transportation situation, in or on the vehicle (Regulation 22). The
performance measure for an extinguisher is that it must be capable of
extinguishing a fully ignited pool of flammable liquid (50mm deep and at
least 6m2 in area), before the extinguisher is exhausted, and when used by
one person (Regulation 23).
Level 3 emergency management requirements – emergency response
plans
These Regulations relate to the requirement for an emergency response plan
to be available at any place (excluding aircraft or ships) where Raid Fast Kill
+ 5 hour Mossie Protection + Natural Pyrethrum is held (or reasonably likely
to be held on occasion) in quantities above 3000 litres aggregate water
capacity (equivalent to 12000 cans of Raid Fast Kill + 5 hour Mossie
Protection + Natural Pyrethrum), using the flammable aerosol level.
The emergency response plan must describe all of the likely emergencies that
may arise from the breach or failure of controls. The type of information that
is required to be included in the plan is specified in Regulations 29 to 30.
Requirements relating to the availability of equipment, materials and people
are provided in Regulation 31, requirements regarding the availability of the
plan are provided in Regulation 32 and requirements for testing the plan are
described in Regulation 33.
Level 3 emergency management requirements – signage
This control relates to the provision of emergency management information
ERMA New Zealand Decision: Application HSR03031
Page 23 of 24
Control
Code1
Regulation2
Explanation3
on signage at places where Raid Fast Kill + 5 hour Mossie Protection +
Natural Pyrethrum is held in quantities above 3000 litres aggregate water
capacity (equivalent to 12000 cans of Raid Fast Kill + 5 hour Mossie
Protection + Natural Pyrethrum), using the flammable aerosol level.
The signage must advise of the action to be taken in an emergency and must
meet the requirements for comprehensibility and clarity as defined in
Regulations 34 and 35 of the Identification Regulations.
Hazardous Substances (Personnel Qualification) Regulations 2001
AH1
Regulations 4- Approved Handler requirements (including test certificate and
6
qualification requirements)
Raid Fast Kill + 5 hour Mossie Protection + Natural Pyrethrum is required to
be under the control of an approved handler during specified parts of the
lifecycle. An approved handler is a person who holds a current test certificate
certifying that they have met the competency requirements specified by the
Personnel Qualification Regulations in relation to handling specific hazardous
substances.
The specific classes and quantities of hazardous substances that trigger
approved handler requirements are listed in the schedules of the relevant
property controls Regulations (Classes 1 to 5 Controls Regulations and Classes
6, 8 and 9 Controls Regulations). The trigger level for Raid Fast Kill + 5 hour
Mossie Protection + Natural Pyrethrum is 3000 L (aggregate water capacity).
This is equivalent to 12000 cans of Raid Fast Kill + 5 hour Mossie
Protection + Natural Pyrethrum.
Regulation 4 describes the test certification requirements, Regulation 5
describes the qualification (competency and skill) requirements and Regulation
6 describes situations where transitional qualifications for approved handlers
apply.
Compressed Gas Regulations
CG
These regulations will provide controls on aerosol containers. They have yet to be enacted.
Additional Controls under Section 77A
Raid Fast Kill + 5 hour Mossie Protection + Natural Pyrethrum must not be applied directly onto or into
water
ERMA New Zealand Decision: Application HSR03031
Page 24 of 24